Enclosure 1 Characterization Summary for AM WTP Container Number BN101610942 

# Characterization Summary for
AMWTP Container Number

BN10161094Characterization Summary for AMWTP Container

Number BN10161094

TABLE OF CONTENTS

1.0 Waste Identification and Segregat ion........................................................................ 2

2.0 Radiological Content ................................................................................................. 3

3.0 Waste Material Parameters ....................................................................................... 6

4.0 Headspace Gas......................................................................................................... 6

5.0 Ignitable, Corrosive and Reactive Waste................................................................... 7

5.1 Ignitabi lity ............................................................................................................ 7

5.2 Corrosivi ty ........................................................................................................... 8

5.3 Reactivi ty ............................................................................................................ 8

6.0 Prohibited Items......................................................................................................... 9

7.0 Waste Compatibility and Characteri zation............................................................... 10

Attachment 1 – RTR Measur ement Contro l Repor t............................................................ 11Characterization Summary for AMWTP Container

Number BN10161094

2 1.0 Waste Identificat ion and Segregation

The Central Characterization Projec t (CCP) Acceptable Knowledge (AK) Summary Report for Rocky Flats Combusti bles and Plastic Stored at the Idaho National Laboratory (INL ), CCP-AK-INL-004, Central Characterization Project Acceptable Knowledge Summary Repor t for Rocky Flats Combustibles and Plastic Stored at the Idaho National Laboratory

, was created to characterize waste from Rocky Flats which includes legacy drum BN10161094 (historical Rocky Flats drum number RF000107529). Waste characterized under that report, including BN10161094, is assigned to waste stream ID-RF-S5300-A. As
described in Section 4.5 of CCP-AK-INL- 004, when waste was initially packaged at Rocky Flats, it was segregated by the type of waste matrix and identified by an item description code (IDC). Once a drum was full, a prefix and serial number were assigned by nuclear material accountability personnel.

IDCs are a series of thr ee-digit numbers used to identify nuclear material forms or process materials. IDC 336, wet combustibles, is assigned to drum
BN10161094. Drum BN101 61094 was originally packaged on November 10,
1972. Section 5.4.1 of CCP-AK-INL-004 describes IDC 336 as combustibles such as cloth, paper, and wood wastes, sorted from dry combustibles (IDC 330)

based on the criteria that wet combusti bles contained a discernable amount of
moisture within the matrix. Combustibl e waste items may include wipes, towels, rags, tape, protective clothing (e.g., glov es, coveralls, booties), filter paper, wood filter frames, cotton swabs, cardboar d, sandpaper, labels, tissue paper, and gasket material (References P001, P004, P008, P015, P024, P032, P052, P063, U512).

The drum prefix corresponds to a ma terial balance account (MBA) used to
control the transfer of nuclear material . The MBA can be correlated to an area within a particular building. The prefix is identified by t he middle part of the container number (i.e., 0001 is the pref ix for drum number RF000107529). The last five digits of the drum number ar e the serial numbers that indicate the sequence in which drums were packaged within a given prefix. Prefix 0001 corresponds to MBA 1371-31, aqueous plutoni um recovery operations in Building
771. As described in Section 4.3 of CCP-AK-INL-004, Building 771 recovery operations used acid to dissolve solid materials containing plutonium. The resulting solutions were processed by a series of ion exchange, precipitation, calcination, fluorination, and reduction operations to produce purified plutonium metal to be recycled back into production operations. Combustible materials were typically generated from gl ovebox housekeeping and maintenance associated with these operat ions (References C170, C184, P024, P053, P061, P067, P090, P163, P502, P505, U059, U069, U097).Characterization Summar

Number BN10161094 y for AMWTP Container

3 2.0 Radiological Content

As described in Section 5.4.2 of CCP-AK-INL-004, the primary radionuclides processed at the Rocky Flats Plant included weapons-grade plutonium (Pu), americium (Am)-241, enriched uranium, and depleted uranium. The approximate isotopic compositions of these material s are presented in Table 5-2 of CCP-AKINL-004 and provided in Table 2-1 below . Historical waste evaluations and packaging procedures indicate waste was counted to determine Pu content prior to shipment off site. The Transurani c Waste Management Information System (TWMIS) database, compiled from shippi ng records for waste containers shipped to INL, identifies no Pu or Am-241 in container BN1016094 and reports the values for both as zero. The detection limit for the counter used by Rocky Flats
had a lower detection limit of 0.7 grams of weapons gra de plutonium. Table 2-2 is a printout of the portion of the TWMIS database containing the drums in shipment 72247B from Rocky Flats to INL in 1972. The database shows that the reported quantities of Pu and Am-241 we re less than the detectable limits; therefore, less than 0.7 gr ams of weapons grade materi als are present in the drum (References C039, C130, P069, P152, P161, P166, P169, P210, P227, U064, U512).

Table 2-1. Isotopic Compositions of Rocky Flats Plutonium and Uranium

Weapons-Grade Plutonium Enriched Uranium Depleted Uranium

Plutonium-238 0.01 –

0.05% Uranium-234 0.1 –

1.02% Uranium-234 0.0006%

Plutonium-239 92.8 –

94.4% Uranium-235 90 – 94% Uranium-235 0.2 – 0.3%

Plutonium-240 4.85 – 6.5% Uranium-236 0.4 –

0.5% Uranium-238 99.7 –

99.8%

Plutonium-241* 0.3 – 1.0% Uranium-238 5.3 –

5.5%

Plutonium-242 0.005 –

0.60%

* includes Am-241 daughter producty for AMWTP ContainerBN10161094Table 2-2 TWMIS Database Shipment 72247BCONTAINER_IDCNTR_NUMCNTR_TYPEIDCPACK_DATEPRIMARY_NUCLIDEPRIMARY_QUANTITYSECONDARY_NUCLIDESECONDARY_QUANTITYSHIP_NUMBERSHIP_DATEGROSS_WEIGHTUPDATE_MONTHRF000107410000107410A33611/4/1972Pu0.00Am-241072247B11728211/1/1972RF000107413000107413A33611/4/1972Pu0.00Am-241072247B11727911/1/1972RF000107415000107415A33611/4/1972Pu0.00Am-241072247B117210011/1/1972RF000107418000107418A33611/4/1972Pu0.00Am-241072247B11727611/1/1972RF000107423000107423A33611/4/1972Pu0.00Am-241072247B11728011/1/1972RF000107424000107424A33611/4/1972Pu2.00Am-241072247B11725611/1/1972RF000107425000107425A33611/5/1972Pu0.00Am-241072247B11726811/1/1972RF000107429000107429A33611/5/1972Pu0.00Am-241072247B11726911/1/1972RF000107430000107430A33611/5/1972Pu0.00Am-241072247B11725811/1/1972RF000107431000107431A33611/5/1972Pu0.00Am-241072247B11726611/1/1972RF000107432000107432A33611/5/1972Pu0.00Am-241072247B11729111/1/1972RF000107433000107433A33611/5/1972Pu2.00Am-241072247B11727311/1/1972RF000107529000107529A33611/10/1972Pu0.00Am-241072247B11726211/1/1972RF000107530000107530A33611/10/1972Pu0.00Am-241072247B11726811/1/1972RF000107531000107531A33611/10/1972Pu0.00Am-241072247B11727411/1/1972RF000107626000107626A33611/15/1972Pu0.00Am-241072247B11726411/1/1972Characterization SummarNumber5 CCP has analyzed the results of ce rtified nondestructive assays (NDA) performed on 136 drums of Rocky Fl ats waste generated and packaged during
the same time frame as BN10161094. These drums were generated from the same processes that produced the subject drum as is ev idenced by the historical identification number prefix of RF0001. These results are summarized in Table

2-3 below.

Table 2-3 Summary of CCP Certif ied NDA for 136 RF0001 IDC-336 Drums
Generated Between 1972 and 1973

Range

Radionuclide/Calculation Average Low High AM-241 (g) 1.11E-04 0.00E+00 2.64E-03 CS-137 (g) 6.07E-12 0.00E+00 2.95E-10 NP-237 (g) 1.60E-05 0.00E+00 2.61E-04 PU-238 (g) 6.45E-06 0.00E+00 2.13E-04 PU-239 (g) 5.21E-02 0.00E+00 1.46E+00 PU-240 (g) 3.09E-03 0.00E+00 9.33E-02 PU-241 (g) 4.77E-05 0.00E+00 1.25E-03 PU-242 (g) 1.54E-05 0.00E+00 4.12E-04 RA-226 (g) 1.53E-09 0.00E+00 1.65E-07 SR-90 (g) 4.25E-12 0.00E+00 2.06E-10 U-232 (g) 4.48E-12 0.00E+00 6.09E-10 U-233 (g) 0.00E+00 0.00E+00 0.00E+00 U-234 (g) 0.00E+00 0.00E+00 0.00E+00 U-235 (g) 0.00E+00 0.00E+00 0.00E+00 U-238 (g) 0.00E+00 0.00E+00 0.00E+00 Plutonium Equivalent Curies (Ci) 4.57E-03 0.00E+00 1.28E-01 Plutonium Fissile Gram Equivalents (g) 5.23E-02 0.00E+00 1.47E+00

g = grams Ci = Curies

Based on these results and the historic al data from the TWMIS database (see Table 2-2) it is reasonable to conclude that the radionuclide content in drum BN10161094 does not pose any unacceptable ri sk for disposal at WIPP. In fact, based on the results of assays from drum s of this type and fr om the Rocky Flats

data on this drum it would be reasonabl e to conclude that drum BN10161094
contains less than the 0. 7 grams of weapons grade Pu as indicated by the
TWMIS data. Based on this and a review of the historical NDA data on similar containers the container will be assigned a calculated value of weapons grade Pu based on the Rocky Flats assay showing less than 0.7 grams of Pu. The weapons grade Pu mass fractions used for this calculation are provided in the
NDA Memorandum for waste stream ID-RF-S5300-A.6 3.0 Waste Material Parameters

Drum BN10161094 was subject to a Real-T ime Radiography (RTR) fast scan per CCP procedure CCP-TP-066, CCP Radiography Screening Procedure for

Prohibited Items . The purpose of this procedure is to identify all prohibited items

within the waste container but it is not intended to satisfy the Waste Analysis Plan (WAP) requirements for identifying waste material parameters within the container. From the proce ss description it is known that the drum contains a debris waste known as wet combustibles. The AK information which supports this is presented above in Section 1.0, Waste Identification and Segregation. In addition, CCP has performed a certifi ed RTR scan on 117 drums that were generated by Rocky Flats during the same ti me frame, have the same IDC, and were from the same process as is evidenc ed by the drum prefix of RF0001. The average results for these drums are presented in Table 3-1.

However, for drum BN10161094 the entire c ontents, or 35.24 Kg will be reported as plastic in WWIS. When compared to the summary data derived from other drums from the same proce ss it is apparent that this assignment is conservative with regard to the am ount of cellulosics, plastics, and rubber (CPR) in this waste stream. Reporting in this manner is al so conservative with regard to the CPR allowed in the repository, as deta iled in Table 4-11 of the Compliance Recertification Application.

Table 3-1 Average Volume % Waste Material Parameters for
117 RF0001 IDC 336 Containers

Waste Material Parameter Average
Volume %

Cellulosics Volume % 55.97%

Plastics Volume % 37.58%

Rubber Volume % 3.15% Organic Matrix Volume % 0.00%
Inorganic Matrix Volume % 0.00%

Iron-based Metals Volume % 0.49%

Al-based Metals Volume % 0.07%

Other Metals Volume % 0.05%
Other Inorganics Volume % 2.69%

Total Volume 100.00%

4.0 Headspace Gas

Container number BN10161094 is included in ID-RF-S5300-A Random Selection Lot 2 but was not selected for headspac e gas sampling since its associated position in the random selection order was number 11,730. This container has met the WAP requirement s regarding headspace gas sampling and analysis.7 5.0 Ignitable, Corrosive and Reactive Waste

5.1 Ignitability

The materials in BN10161094 do not meet the definition of ignitability as
defined in 40 CFR 261.21. Acco rding to Rocky Flats packaging procedures, absorbents (e.g., Oil-Dri or Portland cement) were added to wastes having the potential of generat ing residual liquids (i.e., wet combustibles or plastic bottles contai ning liquid). Residual liquids have
been identified in drums of combusti bles and plastic (IDCs 330, 336, and 337) from Rocky Flats; however, analysis of the liquids did not identify the presence of ignitable liquids. The analyses of these liquids also

determined that water-based solutions were the most common liquids present. The materials in this dr um are not compressed gases. The materials are not capable of causing fire through friction or absorption of moisture. In addition, a review of hi storical AK indicates that ignitable liquids were not used during Buildi ng 771 aqueous Pu recovery operations (References P012, P014, P015, P024, P090, P503, P505).

Prior to 1974, nitric acid (the most common acid used during recovery operations) was not rinsed from combus tibles prior to removal from the glovebox and therefore wet combusti bles (IDC 336) drums generated prior to 1974 may be contaminated with mini mal amounts of nitrate salts. However, nitration of material does not result from casual or incidental contact. Further, any potential for self-i gnition due to nitrate salt formation would have occurred within a relatively short time-frame (i.e., prior to shipment to INL); there has been no observed chemical reaction over the past 35 or more years. As descr ibed below, RTR of drum BN10161094 identified a 1⁄2-cup of liquid in a glass container and 2 tablespoons of liquid in a plastic container. The chemical composition of the liquids was not documented, but based on the waste generating operation, the liquid could potentially be water, nitric acid or sulfuric acid. Nitric acid was the most common acid used in plutonium recovery, but sulfuric acid was also used. The conditions needed to produce nitrocellulose, including the presence of both concentrated nitric ac id and sulfuric acid, were not and are not present. Further, had the formation of nitrocellulose occur, ignition

would be immediate. These acid s were used independently of one another, and therefore, the liquid in thes e inner containers is not expected
to be a nitric/sulfuric acid mixture. Drum BN10161094 is therefore not an ignitable waste (D001) (References C076, P024, P239, P282, P283, P284, P285, U060, U097).8 5.2 Corrosivity

The materials in BN10161094 are not expec ted to meet the definition of corrosivity as defined in 40 CFR 261.22. According to Rocky Flats packaging procedures, absorbents (e.g., Oil-Dri or Portland cement) were added to wastes having the potential of generating residual liquids (i.e., wet combustibles or plastic bottles containing liquid). Residual liquids
have been identified in drums of combustibles and plastic (IDCs 330, 336, and 337) from Rocky Flats; however, analyses of the liquids indicated pH values from 5 to 12, which are not corro sive by definition. The analyses of these liquids also indicate that water-based solutions were the most common liquids present (References P012, P015, P024, P503, U060).

As described in Section 6.0, RTR of drum BN10161094 id entified a 1⁄2-cup of liquid in a glass container and 2 tablespoons of liquid in a plastic container. The chemical compositi on of the liquids was not documented, but based on the waste gener ating operation, the liq uid could potentially be an acid which was commonly used in plutonium recovery. However, acidic liquids used in recovery operations were collected through process drain networks and stored in holding tan ks in the process areas. These tanks were sampled to determine the pl utonium content. If liquids were below the Economic Discard Limit (EDL), they were transferred to Building 774 for treatment, otherwise, the liquids went back through the recovery process. However, since the liqui ds in drum BN101 61094 are in small containers, a more likely scenario is that the liquids are from

decontamination and housekee ping of the plutonium recovery gloveboxes and equipment. Decontamination soluti ons included soap and water, nitric acid, caustic solutions, and KW detergent. KW detergent is a water solution containing citric acid, Ve rsene (a trade name for ethylenediamine tetraacetic acid), and Igepal (a st rong non-toxic detergent or wetting agent) (References P024, P053, P061, P068, P090, P163, U097, U512).

5.3 Reactivity

The materials in BN10161094 do not meet the definition of reactivity as defined in 40 CFR 261.23, and at no time have these materials been managed as reactive wastes. The materials are stable and will not undergo violent chemical change. The materials will not react violently with water, form potentially explosiv e mixtures with water, or generate toxic gases, vapors, or fumes when mix ed with water. The materials are not capable of detonation or explosive reaction and there is no evidence of explosive materials. The materials do not contain sulfide compounds. Trace quantities of cyanide from anal ytical laboratory and electroplating operations may be present in the wa ste stream, but BN10161094 will not contain cyanide because this drum originated from aqueous recovery operations. The materials were generated in 1972 and since then have been packaged, stored, examined, and tran sported multiple times. During this time no documented violent chemical change has been observed in9 this or similar drums. Drum BN1016109 4 is therefore not a reactive waste (D003) (References D003, P012, P015, P024, P052, P081, P284, P285, P501).

6.0 Prohibited Items

Drum BN10161094 was subject to an RTR fast scan per CCP procedure CCPTP-066. The purpose of this procedure is to identify prohibited items within the

waste container but it is not intended to satisfy the WAP characterization requirements. RTR of the materials in BN10161094 identified the presence of containerized liquid (1/2 cup of liquid in a glass container and 2 tablespoons of liquid in a plastic container). The quant ity of liquid identified is less than one percent of the 55-gallon container volu me and is considered to be non-residual liquid because of the amount in the inner container. Additional discussion of this liquid is presented above in Sections 5.1 and 5.2.

The quantity of liquid is only prohibited because it is not a residual liquid remaining in a well-drained internal cont ainer. As discussed above in Section 5.2, the containerized liqui d is most likely a water-based solution, however, if the liquid is corrosive, the current configurat ion is the safest for human, health, and the environment (i.e., the liquid waste would not have the opportunity to corrode
the drum/standard waste box and enter the environmen t). In a worst-case scenario, if the liquid waste is acidic, and is released from the individual internal

containers it would not enter the envir onment. It would most likely not make

contact with the steel drum because of interaction with the other materials in the drum, including absorbent which was typica lly added when liquids were present. This is a very small amount of liquid and most would likely be absorbed by the drum contents. Any traces of acid t hat might reach the drum wall would be neutralized by interaction with the iron drum without affecti ng the standard waste

box.

The procedure requires a full scan of the dr um and identification of all prohibited items. The only prohibit ed item identified for cont ainer BN10161094 was the amount of prohibited li quid identified during the scan. The results of this scan are provided in Attachment 1.10 7.0 Waste Compatibility and Characterization

The chemical characteristics of each waste stream ar e documented on the individual Waste Stream Profile Form, including the Envir onmental Protection Agency (EPA) hazardous waste numbers (HWNs). Because both the sludge waste stream, BNINW216, and the combus tible waste stream, ID-RF-S5300-A, are approved waste streams, there are no issues regarding the chemical compatibility of contai ner BN10161094 with the sludge containers also in the

standard waste box or the r epository. In addition, the EPA HWNs assigned to
waste stream ID-RF-S5300-A bound thos e assigned to the waste stream BNINW216 sludge. Specifically, waste stream ID-RF-S5300-A includes combustible materials generated from the Building 774 aqueous waste treatment operations which generat ed the IDC 002 sludge in waste stream BNINW216. These wastes were segregated and packa ged separately at the point of generation to achieve more accurate drum assay results, not due to any potential chemical compatibility issues. Furt her, the potential sludge content on
combustibles is the basis for the a ssignment of EPA HWNs F006, F007, and

F009 to waste stream RF-I D-S5300-A. The differences in EPA HWNs assigned
to each waste stream result from diffe rences in characterization approaches
rather than chemical content. F003 is conservatively assigned to waste stream BNINW216 based on the potent ial presence of acetone, butanol, ethyl benzene, ethyl ether, methanol, and xylene used at Rocky Flats as solvents. These constituents are also identified as potent ial contaminants of waste stream ID-RFS5300-A. However, F003-listed solvents are listed solely for ignitability, and this waste stream does not exhibit the characteristic of ignitability because the small amount of residual liquid is most lik ely aqueous and is not expected to be a solvent. Therefore, EPA HWN F003 is not assigned to waste stream ID-RFS5300-A. EPA HWNs for organic toxicity characteristic 1,2-dichloroethane (D028) and 1,1-dichloroethylene (D029) are also conservatively assigned to waste stream ID-RF-S5300-A since they ar e identified as potential contaminates

on combustibles in the waste stream. However, since solids analysis data for

waste stream BNINW216 shows these cons tituents were present in the sludge below regulatory levels; these EPA HW Ns were not added to the sludge waste stream. Headspace gas sampling for bot h waste streams has indicated that

there are no additional HW N assignments required beyond what is identified in
CCP-AK-INL-004.Attachment 1 – RTR Measurement Control Report

11Attachment 1 – RTR Measurem ent Control Report (Continued)

12Attachment 1 – RTR Measurem ent Control Report (Continued)

13Enclosure 2 Panel 4, Room 6 Volatile Or ganic Compounds Impact EvaluationImpact Evaluation of Drum BN10161094 on VOC Concentrations in Room 6 of Panel 4

This Volatile Organic Compound (VOC) data evaluation is being made to aid in determination of a path forward in final disposition of the drum BN10161094 that was emplaced in Room 6 of

Panel 4 on June 27 th , 2007. The evaluation compares VOC concentrations in Room 6 of Panel 4 prior to the emplacement of that waste container, and VOC data collected post emplacement.

The disposal room VOC monitoring program consis ts of sampling for VOCs within each room containing waste in an active panel. Each individual room has two sampling points, one at the exhaust side of the room and the other at the inlet side. The exhaust side sampling location is activated upon waste emplacement (RH or CH) within each room. The inlet sampling location is
activated after the room is full and the ventilation barriers have been installed.

The Room 6 exhaust sampling location was activated in early 2007 with the initiation of RH waste emplacement within the room. The room has remained active since the initiation of waste disposal activities. Therefore the inlet sampling location in Room 6 has remained inactive. Sampling at the exhaust side is conducted on a bi-weekly basis.

Drum BN10161094 was disposed of on June 27 th , 2007. Since that time two samples have been collected: July 5 th and July 17th. Of the two samples, results are available for the July 5 th sample. Sample results prior to the disposal of the drum show very low levels of VOCs within the room with four of the nine target VOCs having been detected (Toluene, 1,1,1- trichloroethane, Carbon Tetrachloride, and Methylene Chloride). The remaining five target compounds were not detected in any sample prior to the disposal of the drum in question. Results received from the first sample after the disposal of the drum indicate the VOC room environment has not changed since June 27 th , 2007. The results show detection of Toluene, 1,1,1-trichloroethane, Carbon Tetrachloride, and Methylene Chloride at levels that are lower than the maximum detected concentrations for that room. The results also did not yield detections for any of the five previously undetected target compounds.

Drum BN10161094 did not impact the VOC concentrations in room six of panel four.Enclosure 3
AMWTP CAR #28920 Corrective Ac tion Report Containing the Corrective Action Plan

# CORRECTIVE ACTION

REPORT CAR #: 28920

PARENT:

Finding #: Dumas, Elvin

Source Type: As Found Condition 7/18/2007 2:03:00PM

On 7/16/2007, personnel at the Advanced Mixed Waste Treatment Project (AMWTP) discovered that a shipment of Transuranic Waste (TRU) made on June 23, 2007 to the Waste Isolation Pilot Plant (WIPP) had contained a drum which was not approved to be shipped. This container was shipped in TRUPACT- II cask serial number 190, in shipment IN070356. This condition caused non-compliances with WIPP Program requirements. Therefore, this event was categorized as reportable under ORPS.

During a routine inventory of waste stored at the AMWTP, the production planning manager found a drum that was recorded as having been shipped to WIPP the previous month. Subsequent investigations showed that the drum had been approved to be placed in a Standard Waste Box (SWB) - a type of overpack container - for the shipment, but that another drum had been mistakenly put in the SWB. The drum that was recorded as having been placed in the SWB had not been certified to WIPP program requirements prior to shipment. The container

identification number of this drum is 10161094. The container identification number of the drum that should have been overpacked in the SWB was 10106194.

A fact finding meeting was held the next day. This revealed that an incorrect drum was retrieved from storage for the overpack payload. The operators who retrieved it did not ensure the drum had the proper barcode label (i.e., that the barcode scanned and entered into the Waste Tracking System (WTS) matched the WIPP waste information system (WWIS) build instruction that had been provided by the Transportation Certification Official). This error was further propagated due to the procedure steps for verification that drums being placed into an overpack (SWB or Ten Drum Overpack) match the WWIS build instructions from the Transportation Certification Official (TCO), are not as clearly delineated as the applicable procedure steps for verification of non-overpacked containers.

WIPP Data Incorrect Drum Shipped to Waste Isolation Pilot Plant

Description of CAR: Requirement Violated: Source Type Doc. No. : Date Opened:

Originator: Title:

Category:

ORPS No.: EM-ID--BBWI-AMWTF-2007-0013

MP-TRUW-8.1; MP-TRUW-8.2; MP-TRUW-8.3 ORPS Category: 3

N/A ORPS Reportable: Yes

Manager Review By: Manager Review Date:

QA Closed-Cancelled By: QA Closed-Cancelled Date:

Note: QA Closed-Cancelled Signature is based on concurrence between Responsible Manager and Quality Assurance Elvin Dumas 7/18/2007 3:30:00PM

# CORRECTIVE ACTION

REPORT CAR #: 28920

PARENT:

Is Valid:

Significant :

PAAA Applicable:

PAAA Reportable:

PO Number: Stop Work Order: Yes Yes

Yes

No

Waste Programs Responsible Department:

Operations Group: Operations WIPP Submittal Req'd?:

QA Mgr Rev Sign By: Elvin Dumas QA Mgr Rev Sign Date: 7/18/2007 5:46:00PM Yes

7/20/2007 3:29:00PM Disposition Due Date: 10 CFR 820: 10 CFR 830 Subpart A:

10 CFR 835 Rad Protection: 10 CFR 830 Subpart B:

10 CFR 851Safety/Health: Yes

No

No PAAA Regulations NTS Report Number:

NTS Report Date:

No Yes Yes

# CORRECTIVE ACTION

REPORT CAR #: 28920

PARENT:

Immediate Actions:

1. Suspended all payload assembly activities involving overpacks.

2. Suspended all shipments to WIPP.

Immediate Actions for resumption of shipments:

3. Identified all shipments enroute to WIPP, and received at WIPP but not yet emplaced, that contained overpack payload containers. Eight shipments were identified containing a total of 21 overpack payloads, with 128 inner

containers.

4. Performed a 100% verification of the eight shipments to confirm that all inner containers for all overpack payloads certified in the WWIS are accurately identified in the AMWTP Waste Tracking System (WTS) and were traceable to each of the overpacks.

5. Evaluated the WTS container movement history and confirmed movement of all 128 containers to WMF-635 staging location for overpack.

6. All previously assembled overpack payloads remaining at AMWTP will be reverified to confirm that all inner containers for all overpack payloads are accurately identified in the AMWTP Waste Tracking System against the WWIS approved payload configuration, under the oversight of CBFO designated personnel.

7. Modify INST-OI-21, Payload Assembly and MP-TRUW-8.5, TRU Waste Certification, to incorporate DOE-CBFO directed changes.

8. Provide training to Operations, Transportation Certification, and Shipping personnel on INST-OI-21, Payload Assembly, MP-TRUW-8.5, Waste Certification, and an overview of TRU Program requirements for certification.

Investigative action:

A formal investigation and root cause analysis has been initiated. Reference RCA-07-005.

Investigative Action: Formal Investigation and Root Cause analysis RCA-07-005 was completed and determined that INST-OI-21, Rev. 26; Payload Assembly does not provide sufficient instructions for Non-Facility Operations personnel to confirm containers being loaded into SWBs are the same containers as those identified on the OPCTCD provided by the TCO. Furthermore, the procedure does not explicitly require dual verification of overpacked containers by the TCO.

Root Cause:

A5/B2/C08 - Communication LTA, Written Communication LTA, Incomplete/Situation Not Covered

Contributing Cause(s): Corrective Action

Plan: Root Cause Analysis: Yes

Level A Cause Code: Assigned Actionee: Wale, Doug

Level B Cause Code:

Level C Cause Code: B2 - Written Communication Content LT

C08 - Incomplete/Situation Not Covered A5 - Communications LTA Contibuting Cause Level A:

Contibuting Cause Level B:

Contibuting Cause Level C: Raish, Scott Responsible Manager: Date Due: 10/16/2007

A5 - Communications LTA

B3 - Written Communication Not Us

C01 - Lack of Written Communicatio Con OPs Category: Operations Procedures

# CORRECTIVE ACTION

REPORT CAR #: 28920

PARENT:

1. Previous assessments have not been performed specifically on the payload assembly process as provided in INST-OI-21, Rev. 26; Payload Assembly. A4/B1/C04 - Management Problem, Management Methods LTA, Management Follow Up/Monitoring of Activities did not identify problems

2. Manual entry of containers identified on the OPCTCD into WTS to query for container location results in wrong container retrieved from storage. A3/B1/C01 - Human Performance LTA, Skill Based Error, Check of Work LTA

3. There is no formal process/procedure for development, control, and issue of the Production Planning Payload Build Report and subsequent hand-off to Operations. A5/B3/C01 - Communication LTA, Written Communication Not Used, Lack of Written Communication

Investigative and Remedial Actions: In addition to the Immediate actions, the following Investigative Actions will be implemented to determine Extent of

Condition:

1. A physical verification of 55 and 83 gallon containers in storage at WMF-610, WMF-628, WMF-629, WMF-630, WMF-631, WMF-632, WMF-633, WMF-634, WMF-635, WMF-636, and WMF-676 will be performed in accordance with the AMWTP Drum Physical Inventory Plan, AMWTP-PLN-016 in comparison to the Waste Tracking System electronic data to reconcile the inventory balance.

a. Physical verification of the inventory in the identified storage modules. Actionee: J. Mousseau/Plant Manager Completion Date: 7/26/07

b. A final report will be issued to document the results of the inventory validation and reconciliation of any

identified anomalies. Actionee: S. Raish/Waste Programs Manager Completion Date: 8/3/07

2. As a Remedial Action, a Short Term Instruction will be issued to direct movement of containers using only move sheets from production planning. Actionee: D. Wale/Operations Manager Completion Date: 7/26/07

Actions to Preclude Recurrence:

(Note that the root cause is addressed in the Immediate Action, Item # 7)

3. Establish waste storage rows for certified containers and implement controls to ensure that containers sent to WMF-635 for payload assembly are retrieved only from the established certified container storage rows. Actionee: C. Sisson/Production Planning Completion Date: 8/1/07

4. Certified container rows will be roped and clearly marked as such. Actionee: C. Sisson/Production Planning Completion Date: 8/1/07

5. All storage rows containing reject containers (i.e. nonconforming) will be roped off, clearly marked as containing rejected containers, and containers identified on a row map. Actionee: C. Sisson/Production Planning Completion Date: 8/1/07

# CORRECTIVE ACTION

REPORT CAR #: 28920

PARENT:

6. All storage modules that do not contain certified waste will be posted at the entrances to alert personnel that the building does not contained certified drums. Actionee: C. Sisson/Production Planning Action Completed: 7/24/07

7. Establish a Production Planning procedure to standardize and control the issuance of container move orders. Actionee: R. Hose/Production Planning and Project Integration Manager Completion Date: 8/24/07

8. Provide training to Operations personnel on the requirements of INST-OI-11, Waste Container Handling. Actionee: D. Croft/Waste Processing Action Completed: 7/19/07

9. Schedule Management Assessments for effectiveness review of changes and corrective actions for TRUPACT-II loading, payload assembly, certification, and shipping procedures and processes. These assessments will evaluate the corrective actions taken for CAR 28920 to ensure actions taken and procedural controls implemented, will effectively prevent recurrence. Actionees: J. Mousseau/Plant Manager and S. Raish/Waste Programs Manager Completion Date: 10/12/07

10. Develop an implementation plan/schedule to transition to CCP Transportation Authorization with concurrence from DOE-ID, DOE-ID Contracting Officer and CBFO. Actionee: S. Raish/Waste Programs Manager Completion Date: 8/10/07

Elvin Dumas

7/25/2007 4:12:00PM 7/25/2007 4:10:00PM

Scott Raish 7/25/2007 2:21:00PM Scott Raish Mgr Disp App Date:

QA Mgr Rev Disp Sign Date: Mgr Disp App By:

QA Mgr Rev Disp Sign By:

QA Add'l Disp. Req'd By: QA Add'l Disp. Req'd Date:

Mgr Add'l. Disp App By: Mgr Add'l. Disp App Date:

CAP Complete Comments:

Action Complete By: Action Complete Date:

QA Add'l Action Req'd By: QA Add'l Action Req'd Date:

Add'l Action Complete By: Add'l Action Complete Date:

QA Verification Complete By: QA Verification Comp Date: